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CMS Adequacy Reference

The network ops team's guide to CMS MA adequacy standards.

A plain-English reference to HSD specialty categories, time-distance thresholds, and county classifications — updated for the 2026 benefit year.

22 HSD specialtiesUrban / Suburban / Rural thresholdsUpdated for 2026
Specialty Categories

The 22 HSD Specialty Categories

CMS requires Medicare Advantage plans to maintain a contracted network across these 22 specialty types. Each carries distinct time-and-distance thresholds depending on county classification.

#SpecialtyCategory Urban Suburban RuralBlueprint Tracks
1Primary Care PhysiciansPrimary Care10mi / 30min15mi / 40min60mi / 90min Yes
2OB/GYNSpecialist15mi / 30min20mi / 40min60mi / 90min Yes
3CardiologySpecialist15mi / 30min20mi / 40min60mi / 90min Yes
4DermatologySpecialist15mi / 30min20mi / 40min75mi / 120min Yes
5EndocrinologySpecialist15mi / 30min25mi / 45min75mi / 120min Yes
6GastroenterologySpecialist15mi / 30min20mi / 40min60mi / 90min Yes
7Hematology/OncologySpecialist15mi / 30min20mi / 40min75mi / 120min Yes
8Infectious DiseaseSpecialist15mi / 30min25mi / 45min75mi / 120min Yes
9Internal MedicinePrimary Care10mi / 30min15mi / 40min60mi / 90min Yes
10NephrologySpecialist15mi / 30min20mi / 40min75mi / 120min Yes
11NeurologySpecialist15mi / 30min25mi / 45min75mi / 120min Yes
12OphthalmologySpecialist15mi / 30min20mi / 40min75mi / 120min Yes
13Orthopedic SurgerySpecialist15mi / 30min20mi / 40min75mi / 120min Yes
14Otolaryngology (ENT)Specialist15mi / 30min25mi / 45min75mi / 120min Yes
15PsychiatryMental Health15mi / 30min20mi / 40min60mi / 90min Yes
16Mental Health/CounselingMental Health15mi / 30min20mi / 40min60mi / 90min Yes
17PulmonologySpecialist15mi / 30min25mi / 45min75mi / 120min Yes
18RheumatologySpecialist15mi / 30min25mi / 45min75mi / 120min Yes
19UrologySpecialist15mi / 30min20mi / 40min75mi / 120min Yes
20Physical TherapyAncillary15mi / 30min20mi / 40min60mi / 90min Yes
21Skilled Nursing FacilityAncillary10mi / 30min20mi / 40min75mi / 120min Yes
22Hospital (Inpatient)Specialist15mi / 30min25mi / 45min75mi / 120min Yes
Thresholds shown are maximums — a plan must satisfy EITHER the distance OR the time threshold for each county and specialty.
County Classification

How CMS classifies counties

CMS uses CBSA (Core-Based Statistical Area) designations and RUCA (Rural-Urban Commuting Area) codes to assign every U.S. county to one of three classifications. The classification determines which time-and-distance thresholds apply.

CBSA Core
Urban

≥ 50,000 population

Urban counties are core-based statistical area (CBSA) cores — metro and micropolitan statistical areas. They have the tightest time-and-distance thresholds because providers are generally close to beneficiaries.

Tightest thresholds

CBSA Noncore
Suburban

Adjacent to urban core

Suburban counties are adjacent to an urban core but classified as CBSA noncore. They carry mid-range thresholds that reflect moderate provider density — wider than urban but tighter than rural.

Mid-range thresholds

RUCA 4–10
Rural

Non-CBSA counties

Rural counties are non-CBSA areas classified by Rural-Urban Commuting Area (RUCA) codes 4–10. They carry the widest thresholds and are eligible for adequacy exceptions when no providers exist within those thresholds.

Widest thresholds + exception eligible

Blueprint pre-loads county classifications for all 50 states. You don't need to look up CBSA or RUCA codes — the correct thresholds apply automatically based on each county in your service area.

Measurement Methodology

How CMS measures time-distance compliance

CMS measures compliance using straight-line (geodetic) distance between the beneficiary's residence and the nearest contracted provider, alongside estimated drive time derived from road network data. A plan must satisfy either the distance threshold or the time threshold — not both simultaneously. Every beneficiary in the service area must have a contracted provider within one of those limits for each required specialty.

adequacy-check · example
01County       Maricopa County, AZ// Urban
02Specialty     Cardiology
03Threshold     15 miles OR 30 minutes
04Nearest provider8 miles · 18 minutes
05Status        ADEQUATE ✓// both distance and time within threshold
Exception Scenarios

When adequacy exceptions apply

CMS recognizes that certain markets cannot support full adequacy compliance. Three exception pathways are available — each requires documentation and CMS review.

Good-Faith Effort Documentation

When no providers are available within the applicable time-and-distance thresholds, plans may apply for an exception by documenting a good-faith effort to recruit providers. This typically requires evidence of outreach to all known providers in the area, including dates, contacts, and responses.

Telehealth Exceptions

Post-COVID regulatory flexibility allows behavioral health specialties (and certain other categories) to count telehealth providers toward adequacy in areas where in-person access is limited. Plans must demonstrate member access to synchronous telehealth and document member notification.

Low-Volume / Market Absence Exception

When a required specialty simply does not exist in the market area — no contracted or non-contracted providers within any distance — CMS may grant a market-absence exception. Plans still must document that no providers operate in the service area and explain how members access care.

HSD Reference File

What the HSD Reference File is — and how Blueprint uses it

CMS releases the Health Service Delivery (HSD) Reference File each fall for the upcoming benefit year. It is the authoritative source for all network adequacy requirements — specifying which specialty categories are required, the exact time-and-distance thresholds for each category and county classification, and which counties qualify for which exceptions.

Annual Release Cycle

CMS typically publishes the HSD Reference File in October or November each year. Plans preparing for the following benefit year's submission must use the most recently released version. Thresholds can shift year over year — particularly for mental health and specialty categories — making it critical to stay current.

How Blueprint applies it

Blueprint loads the HSD Reference File and applies it automatically to your adequacy scoring. Every county in your service area gets the correct thresholds for your LOB — no spreadsheet lookups, no manual configuration.

Blueprint updates HSD thresholds every October when CMS releases the new benefit year reference file. Your scores automatically reflect current requirements — no manual updates required.

Blueprint handles all of this automatically.

Stop managing thresholds in spreadsheets.

Blueprint pre-loads every CMS HSD threshold, classifies every county, and scores your network against current requirements — in real time as you contract providers.